2022-004 ? Special Provisions ? Wage Rate Requirements Federal agency: U.S. Department of Education Federal program title: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U and 84.425W Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): S425C210015 and S425D210045 Award Period: July 1, 2021 - June 30, 2022 Type of Finding: ? Significant deficiency in internal control over compliance Criteria or Specific Requirement: Per 29 CFR Part 5, 2 CFR Part 176, subpart C and 2 CFR section 200.326, the District is required to include in their construction contract subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the Department of Labor regulations. This includes a requirement for the contractor or subcontractor to submit the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance. Condition: During special provisions testing, it was noted that the District has the correct wording relating to the wage rate requirements in the contracts but did not obtain any documentation from the contractor ensuring that the contractor was following the wage rate requirements. Questioned Costs: Not applicable. Context: 1 out of 1 contractor selected has the proper wording relating to the Wage Rate Requirements in the contract but the District does not receive any documentation verifying the compliance. Cause: Oversight. Effect: Lack of proper documentation of controls over compliance with special provision requirements could result in paying contractors that are not in compliance with the Wage Rate Requirements set by the Department of Labor. This could ultimately result in questioned costs. Repeat Finding: Not applicable. Recommendation: We recommend that the District obtain the weekly payrolls and statement of compliance from contractors that work on construction contracts financed by federal assistance funds. Views of Responsible Official: There is no disagreement with the finding.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Current Year Findings 2022-001: Material Weakness ? Davis-Bacon Wage Rate Requirements Federal Assistance Listing Number 84.425D/84.425U/84.425W ? COVID-19 Education Stabilization Fund Passed-through Tennessee Department of Education Award Number S425D210047/S425D200047/S425D2000047/S425U210047/S425W210044-21A Federal Assistance Listing Number 93.323 ? COVID-19 Epidemiology and Laboratory Capacity Grant Passed-through Tennessee Department of Health Award Number N/A Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context: The School did not have internal controls in place to identify that certified payrolls were obtained from contractors on a weekly basis and reviewed in a timely manner. Education Stabilization Fund Cluster - the School did not obtain certified payrolls on a weekly basis for two out of two contractors selected for testing. Additionally, we noted one contractor did not sign the payroll reports, which is required to complete the certification, prior to the audit. Epidemiology and Laboratory Capacity Grant - the School did not obtain certified payrolls on a weekly basis for three contractors under this grant. The School also did not include wage requirement clauses in the contract agreement (as specified in the above Criteria) for the one contract under this grant. Additionally, we noted two contractors did not sign the payroll reports, which is required to complete the certification, prior to the audit. Questioned Costs: Unknown. Effect: The School is not in compliance with Davis-Bacon requirements. Cause: The School was unaware of the requirements as it applied to the grants and as such, there was no assigned department or employee to monitor, review, and obtain certified payrolls and contracts during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the School implement internal controls over wage rate requirements, including tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions. Prior Year Findings None reported
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Current Year Findings 2022-001: Material Weakness ? Davis-Bacon Wage Rate Requirements Federal Assistance Listing Number 84.425D/84.425U/84.425W ? COVID-19 Education Stabilization Fund Passed-through Tennessee Department of Education Award Number S425D210047/S425D200047/S425D2000047/S425U210047/S425W210044-21A Federal Assistance Listing Number 93.323 ? COVID-19 Epidemiology and Laboratory Capacity Grant Passed-through Tennessee Department of Health Award Number N/A Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context: The School did not have internal controls in place to identify that certified payrolls were obtained from contractors on a weekly basis and reviewed in a timely manner. Education Stabilization Fund Cluster - the School did not obtain certified payrolls on a weekly basis for two out of two contractors selected for testing. Additionally, we noted one contractor did not sign the payroll reports, which is required to complete the certification, prior to the audit. Epidemiology and Laboratory Capacity Grant - the School did not obtain certified payrolls on a weekly basis for three contractors under this grant. The School also did not include wage requirement clauses in the contract agreement (as specified in the above Criteria) for the one contract under this grant. Additionally, we noted two contractors did not sign the payroll reports, which is required to complete the certification, prior to the audit. Questioned Costs: Unknown. Effect: The School is not in compliance with Davis-Bacon requirements. Cause: The School was unaware of the requirements as it applied to the grants and as such, there was no assigned department or employee to monitor, review, and obtain certified payrolls and contracts during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the School implement internal controls over wage rate requirements, including tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions. Prior Year Findings None reported
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Current Year Findings 2022-001: Material Weakness ? Davis-Bacon Wage Rate Requirements Federal Assistance Listing Number 84.425D/84.425U/84.425W ? COVID-19 Education Stabilization Fund Passed-through Tennessee Department of Education Award Number S425D210047/S425D200047/S425D2000047/S425U210047/S425W210044-21A Federal Assistance Listing Number 93.323 ? COVID-19 Epidemiology and Laboratory Capacity Grant Passed-through Tennessee Department of Health Award Number N/A Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context: The School did not have internal controls in place to identify that certified payrolls were obtained from contractors on a weekly basis and reviewed in a timely manner. Education Stabilization Fund Cluster - the School did not obtain certified payrolls on a weekly basis for two out of two contractors selected for testing. Additionally, we noted one contractor did not sign the payroll reports, which is required to complete the certification, prior to the audit. Epidemiology and Laboratory Capacity Grant - the School did not obtain certified payrolls on a weekly basis for three contractors under this grant. The School also did not include wage requirement clauses in the contract agreement (as specified in the above Criteria) for the one contract under this grant. Additionally, we noted two contractors did not sign the payroll reports, which is required to complete the certification, prior to the audit. Questioned Costs: Unknown. Effect: The School is not in compliance with Davis-Bacon requirements. Cause: The School was unaware of the requirements as it applied to the grants and as such, there was no assigned department or employee to monitor, review, and obtain certified payrolls and contracts during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the School implement internal controls over wage rate requirements, including tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions. Prior Year Findings None reported
2022-01 Prevailing Wage Rate Internal Control and Compliance CFDA Number: 84.425D Federal Award Number: 036-0648-92-2021 Federal Agency: U.S. Department of Education Pass-through Entity: Montana Office of Public Instruction Condition: The District did not require a contract indicating the requirement of prevailing wage rate and weekly certified payrolls submitted for federal construction project with contractor. Context: During the testing of expenditures for the ESSER projects we noted construction projects with labor in excess of $2,000. Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141--3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Effect: The District was not in compliance with the prevailing wage rate requirement and the internal control system of the District did not identify the need for the compliance. Cause: Internal control procedures were not in place to ensure a contract was draw up to include the prevailing wage rate clause and to ensure the weekly certified payrolls were submitted to the District. Recommendation: The District should implement internal control procedures for any construction contracts in excess of $2,000 funded with federal monies include a contract with the prevailing wage rate clause and submission of weekly certified payrolls.
2022-01 Prevailing Wage Rate Internal Control and Compliance CFDA Number: 84.425D Federal Award Number: 036-0648-92-2021 Federal Agency: U.S. Department of Education Pass-through Entity: Montana Office of Public Instruction Condition: The District did not require a contract indicating the requirement of prevailing wage rate and weekly certified payrolls submitted for federal construction project with contractor. Context: During the testing of expenditures for the ESSER projects we noted construction projects with labor in excess of $2,000. Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141--3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Effect: The District was not in compliance with the prevailing wage rate requirement and the internal control system of the District did not identify the need for the compliance. Cause: Internal control procedures were not in place to ensure a contract was draw up to include the prevailing wage rate clause and to ensure the weekly certified payrolls were submitted to the District. Recommendation: The District should implement internal control procedures for any construction contracts in excess of $2,000 funded with federal monies include a contract with the prevailing wage rate clause and submission of weekly certified payrolls.
2022-01 Prevailing Wage Rate Internal Control and Compliance CFDA Number: 84.425D Federal Award Number: 036-0648-92-2021 Federal Agency: U.S. Department of Education Pass-through Entity: Montana Office of Public Instruction Condition: The District did not require a contract indicating the requirement of prevailing wage rate and weekly certified payrolls submitted for federal construction project with contractor. Context: During the testing of expenditures for the ESSER projects we noted construction projects with labor in excess of $2,000. Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141--3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Effect: The District was not in compliance with the prevailing wage rate requirement and the internal control system of the District did not identify the need for the compliance. Cause: Internal control procedures were not in place to ensure a contract was draw up to include the prevailing wage rate clause and to ensure the weekly certified payrolls were submitted to the District. Recommendation: The District should implement internal control procedures for any construction contracts in excess of $2,000 funded with federal monies include a contract with the prevailing wage rate clause and submission of weekly certified payrolls.
2022-002 Airport Improvement Program ? 20.106 Significant Deficiency: Condition: The Airport did not obtain copies of certified payroll reports from the contractor on a construction project occurring during the period. Context and Criteria: Nonfederal entities engaging in construction contracts in excess of $2,000 are required to receive weekly payroll records and a statement of compliance (certified payrolls) from the construction contractor(s) as required by 2 CFR Part 176, Subpart C (2 CFR section 200.326) for compliance with uniform guidance. Cause: Program employees were not provided weekly certified payrolls by the construction contractor. Effect: The Airport was not in compliance with 2 CFR section 200 for the administration of federal awards. Recommendation: Procedures should be put in place to ensure weekly certified payrolls are received from construction contractors.
Finding: 2022-004 Special Provisions ? Wage Rate Requirements Federal agency: U.S. Department of Education Federal program name: Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D and 84.425U Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): S425D210045 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per 29 CFR Part 5, 2 CFR Part 176, subpart C, and 2 CFR section 200.326, the District is required to include in their construction contract subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the Department of Labor regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance. Condition: During special provisions testing, it was noted that the District has the correct wording relating to the Wage Rate Requirements in the contracts but does not obtain any documentation from the contractor. Questioned Costs: Not applicable. Context: During our testing of special provisions, it was noted that 2 of 2 contractors selected had the proper wording relating to the Wage Rate Requirements in the contract but the District did not receive any documentation verifying the compliance. Cause: Oversight. Effect: Lack of proper documentation of controls over compliance with special provision requirements could result in paying contractors that are not in compliance with the Wage Rate Requirements set by the Department of Labor. This could ultimately result in questioned costs. Repeat Finding: Not applicable. Recommendation: We recommend that the District obtain the weekly payrolls and statement of compliance from contractors that work on construction contracts financed by federal assistance funds. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding: 2022-004 Special Provisions ? Wage Rate Requirements Federal agency: U.S. Department of Education Federal program name: Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D and 84.425U Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): S425D210045 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per 29 CFR Part 5, 2 CFR Part 176, subpart C, and 2 CFR section 200.326, the District is required to include in their construction contract subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the Department of Labor regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance. Condition: During special provisions testing, it was noted that the District has the correct wording relating to the Wage Rate Requirements in the contracts but does not obtain any documentation from the contractor. Questioned Costs: Not applicable. Context: During our testing of special provisions, it was noted that 2 of 2 contractors selected had the proper wording relating to the Wage Rate Requirements in the contract but the District did not receive any documentation verifying the compliance. Cause: Oversight. Effect: Lack of proper documentation of controls over compliance with special provision requirements could result in paying contractors that are not in compliance with the Wage Rate Requirements set by the Department of Labor. This could ultimately result in questioned costs. Repeat Finding: Not applicable. Recommendation: We recommend that the District obtain the weekly payrolls and statement of compliance from contractors that work on construction contracts financed by federal assistance funds. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding: 2022-004 Special Provisions ? Wage Rate Requirements Federal agency: U.S. Department of Education Federal program name: Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D and 84.425U Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): S425D210045 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per 29 CFR Part 5, 2 CFR Part 176, subpart C, and 2 CFR section 200.326, the District is required to include in their construction contract subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the Department of Labor regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance. Condition: During special provisions testing, it was noted that the District has the correct wording relating to the Wage Rate Requirements in the contracts but does not obtain any documentation from the contractor. Questioned Costs: Not applicable. Context: During our testing of special provisions, it was noted that 2 of 2 contractors selected had the proper wording relating to the Wage Rate Requirements in the contract but the District did not receive any documentation verifying the compliance. Cause: Oversight. Effect: Lack of proper documentation of controls over compliance with special provision requirements could result in paying contractors that are not in compliance with the Wage Rate Requirements set by the Department of Labor. This could ultimately result in questioned costs. Repeat Finding: Not applicable. Recommendation: We recommend that the District obtain the weekly payrolls and statement of compliance from contractors that work on construction contracts financed by federal assistance funds. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding: 2022-004 Special Provisions ? Wage Rate Requirements Federal agency: U.S. Department of Education Federal program name: Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D and 84.425U Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): S425D210045 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per 29 CFR Part 5, 2 CFR Part 176, subpart C, and 2 CFR section 200.326, the District is required to include in their construction contract subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the Department of Labor regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance. Condition: During special provisions testing, it was noted that the District has the correct wording relating to the Wage Rate Requirements in the contracts but does not obtain any documentation from the contractor. Questioned Costs: Not applicable. Context: During our testing of special provisions, it was noted that 2 of 2 contractors selected had the proper wording relating to the Wage Rate Requirements in the contract but the District did not receive any documentation verifying the compliance. Cause: Oversight. Effect: Lack of proper documentation of controls over compliance with special provision requirements could result in paying contractors that are not in compliance with the Wage Rate Requirements set by the Department of Labor. This could ultimately result in questioned costs. Repeat Finding: Not applicable. Recommendation: We recommend that the District obtain the weekly payrolls and statement of compliance from contractors that work on construction contracts financed by federal assistance funds. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding: 2022-004 Special Provisions ? Wage Rate Requirements Federal agency: U.S. Department of Education Federal program name: Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D and 84.425U Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): S425D210045 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per 29 CFR Part 5, 2 CFR Part 176, subpart C, and 2 CFR section 200.326, the District is required to include in their construction contract subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the Department of Labor regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance. Condition: During special provisions testing, it was noted that the District has the correct wording relating to the Wage Rate Requirements in the contracts but does not obtain any documentation from the contractor. Questioned Costs: Not applicable. Context: During our testing of special provisions, it was noted that 2 of 2 contractors selected had the proper wording relating to the Wage Rate Requirements in the contract but the District did not receive any documentation verifying the compliance. Cause: Oversight. Effect: Lack of proper documentation of controls over compliance with special provision requirements could result in paying contractors that are not in compliance with the Wage Rate Requirements set by the Department of Labor. This could ultimately result in questioned costs. Repeat Finding: Not applicable. Recommendation: We recommend that the District obtain the weekly payrolls and statement of compliance from contractors that work on construction contracts financed by federal assistance funds. Views of Responsible Officials: There is no disagreement with the audit finding.
REFERENCE: 2022-101 CFDA NUMBER 84.425d ? COVID 19 ? EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION ? 2022 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 QUESTIONED COSTS N/A CONDITION Weekly certified payroll reports were not obtained from the construction contractor to be reviewed for compliance with Davis-Bacon prevailing wage rate requirements from the start of construction in June 2022 through July 2022. The certified payroll reports were obtained on July 29, 2022 and reviewed by the School?s staff. CRITERIA In accordance with 29 CFR Subtitle A, Part 5, Subpart A Davis-Bacon and Related Acts Provisions and Procedures, ? 5.5(a)(3)(ii)(A), the contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). The payrolls submitted shall set out accurately and completely all of the information required to be maintained under 29 CFR 5.5(a)(3)(i), except that full social security numbers and home addresses shall not be included on weekly transmittals. Instead the payrolls shall only need to include an individually identifying number for each employee (e.g., the last four digits of the employee's social security number). The required weekly payroll information may be submitted in any form desired. In accordance with 29 CFR Subtitle A, Part 5, Subpart A Davis-Bacon and Related Acts Provisions and Procedures, ? 5.5(a)(3)(ii)(B), Each payroll submitted shall be accompanied by a ?Statement of Compliance,? signed by the contractor or subcontractor or his or her agent who pays or supervises the payment of the persons employed under the contract and shall certify the following: (1) That the payroll for the payroll period contains the information required to be provided under ? 5.5 (a)(3)(ii) of Regulations, 29 CFR part 5, the appropriate information is being maintained under ? 5.5 (a)(3)(i) of Regulations, 29 CFR part 5, and that such information is correct and complete; (2) That each laborer or mechanic (including each helper, apprentice, and trainee) employed on the contract during the payroll period has been paid the full weekly wages earned, without rebate, either directly or indirectly, and that no deductions have been made either directly or indirectly from the full wages earned, other than permissible deductions as set forth in Regulations, 29 CFR part 3; (3) That each laborer or mechanic has been paid not less than the applicable wage rates and fringe benefits or cash equivalents for the classification of work performed, as specified in the applicable wage determination incorporated into the contract. In accordance with OMB Compliance Supplement, Part 4 ? Wage Requirements Cross-Cutting Section, Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In accordance with OMB Compliance Supplement, Part 6 ? Internal Control, non-Federal entities receiving Federal awards establish and maintain internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. EFFECT Program requirements were not complied with. The School may not complied with prevailing wage requirements. CAUSE Internal controls were not designed appropriately to ensure that documentation was obtained weekly for certified payroll reports to ensure compliance with prevailing wage requirements. RECOMMENDATION AND BENEFIT A process should be developed to obtain and review weekly certified payroll reports for construction services subject to Davis-Bacon. Documentation supporting prevailing wage requirements should be retained. This will help ensure that program and prevailing wage requirements are complied with. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding 2022-004 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Questioned Costs: ALN 84.027 - $173,812.24. Context: Out of seven procurement which were tested, we noted five of them for which the District did not retain documentation detailing the history of the procurement, including the rationale for choosing the particular vendor. Cause: The District during the pandemic and shortly thereafter, was not able to properly ensure all contracts has procurement documentation retained and performed as required by the Uniform Guidance. Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-012 in the previous report for fiscal year 2021. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-004 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Questioned Costs: ALN 84.027 - $173,812.24. Context: Out of seven procurement which were tested, we noted five of them for which the District did not retain documentation detailing the history of the procurement, including the rationale for choosing the particular vendor. Cause: The District during the pandemic and shortly thereafter, was not able to properly ensure all contracts has procurement documentation retained and performed as required by the Uniform Guidance. Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-012 in the previous report for fiscal year 2021. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of responsible officials: There is no disagreement with the audit finding.
Finding 2022-004 Federal agency: U.S. Department of Education Federal program name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220087, H173A190086, 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number: H027A190087, H173A180086 Award Period: Fiscal year 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at CFR sections 200.318 through 200.326. This includes utilizing one of the five allowable procurement methods, including small purchase guidelines for items over the micro-purchase threshold and sealed bids, competitive proposals, or noncompetitive proposals when items exceed the simplified acquisition threshold. In addition, the Uniform Guidance requires that the entity maintain records sufficient to detail the history of the procurement. Condition: During our testing of the District?s procurements within the Special Education program, it was noted that not all procurements followed the appropriate method and history of the transaction was not sufficiently documented. Questioned Costs: ALN 84.027 - $173,812.24. Context: Out of seven procurement which were tested, we noted five of them for which the District did not retain documentation detailing the history of the procurement, including the rationale for choosing the particular vendor. Cause: The District during the pandemic and shortly thereafter, was not able to properly ensure all contracts has procurement documentation retained and performed as required by the Uniform Guidance. Effect: The District was not in compliance with Uniform Guidance requirements for the proper documentation of all procurement transactions. Repeat Finding: Yes, this is a repeat finding. It was presented as Finding 2021-012 in the previous report for fiscal year 2021. Recommendation: We recommend the District reviews its procedures and controls over procurement to ensure that all procurements are documented such that a third party can clearly see and understand the detailed history of the procurement. Views of responsible officials: There is no disagreement with the audit finding.
2022-07 Non-compliance with Wage Rate Requirements CFDA Title: Impact Aid CFDA Number: 84.041 Federal Award Number: 2022 Federal Agency: U.S. Department of Education Pass-through Entity: Direct Condition: The District did not require certified weekly payrolls for claims paid related to fixing a water line and electrical upgrades paid with Impact Aid funding. Context: During testing of the Impact Aid expenditures, we noted two vendors related to construction/remodeling. Criteria: Compliance Requirements ? Section 7007 construction funds, as well as any Section 7002 or 7003(b) funds spent for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Compliance Requirement ? All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141-3144, 3146, and 3147). Non-federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR part 215, Appendix A, Contract Provisions); 2 CFR part 176, subpart C; and 2 CFR section 200.326). Effect: The District was not in compliance with the Wage Rate Requirement. Cause: The vendors did not submit the weekly certified payroll reports and the District?s internal control system did not detect the error. Recommendation: The District should require all Impact Aid fund expenditures for construction or minor remodeling to be subject to the Wage Rate Requirements.
Federal Agency: United States Department of Treasury Federal Program Name: COVID 19 - Coronavirus State and local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number(s): 12060-OPM20600-29669 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Town should have internal controls designed to ensure compliance with those provisions. Condition: The Town?s procurement standards do not include the required elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None Context: Although the Town did not have a policy in place in conformity with the Federal Uniform Guidance criteria, the Town did follow its own procedures as it relates to the contracts under the procurements applicable to the Town?s major programs. Cause: The Town did not formally update their procurement policy as any federal grants they receive in which procurement is required, the appropriate language is included in the grant requirements and documents. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-002. Recommendation: We recommend that the Town review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
Federal Agency: United States Department of Treasury Federal Program Name: COVID 19 - Coronavirus State and local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: State of Connecticut Office of Policy and Management Pass-Through Number(s): 12060-OPM20600-29669 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The Town should have internal controls designed to ensure compliance with those provisions. Condition: The Town?s procurement standards do not include the required elements as outlined in 2 CFR sections 200.318 through 200.326. Questioned costs: None Context: Although the Town did not have a policy in place in conformity with the Federal Uniform Guidance criteria, the Town did follow its own procedures as it relates to the contracts under the procurements applicable to the Town?s major programs. Cause: The Town did not formally update their procurement policy as any federal grants they receive in which procurement is required, the appropriate language is included in the grant requirements and documents. Effect: The auditor noted no instances of noncompliance with the provisions of procurement, suspension, and debarment; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-002. Recommendation: We recommend that the Town review its formal procurement policies and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Views of responsible officials: Management agrees with this finding.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
2022-003 Prevailing Wage Rate Internal Control and Compliance CFDA Title: ESSER II CFDA Number: 84.425D Federal Award Number: 036-0648-92-2021 Federal Agency: U.S. Department of Education Pass-through Entity: Montana Office of Public Instruction Condition: The District did not require a contract indicating the requirement of prevailing wage rate and weekly certified payrolls submitted for federal construction project with contractor. Context: During the testing of expenditures for the ESSER projects we noted construction projects with labor in excess of $2,000. Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141--3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Effect: The District was not in compliance with the prevailing wage rate requirement and the internal control system of the District did not identify the need for the compliance. Cause: Internal control procedures were not in place to ensure a contract was draw up to include the prevailing wage rate clause and to ensure the weekly certified payrolls were submitted to the District. Recommendation: The District should implement internal control procedures for any construction contracts in excess of $2,000 funded with federal monies include a contract with the prevailing wage rate clause and submission of weekly certified payrolls.
Department of Agriculture, passed through Minnesota Department of Education Federal Financial Assistance Listing/CFDA Number 10.553/10.555 Child Nutrition Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension, and debarment it was identified that there was no review of vendors to ensure that they are not suspended or debarred before purchases are made. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported Context/Sampling - Overall procurement policy. Repeat Finding from Prior Years - No Recommendation - We recommend that management establish a formal process to review vendors before purchases are made to ensure they are not suspended or debarred and are in compliance with the Uniform Guidance and 2 CFR sections 200.318 through 200.326. Views of Responsible Officials - There is no disagreement with the audit finding.
Department of Agriculture, passed through Minnesota Department of Education Federal Financial Assistance Listing/CFDA Number 10.553/10.555 Child Nutrition Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension, and debarment it was identified that there was no review of vendors to ensure that they are not suspended or debarred before purchases are made. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported Context/Sampling - Overall procurement policy. Repeat Finding from Prior Years - No Recommendation - We recommend that management establish a formal process to review vendors before purchases are made to ensure they are not suspended or debarred and are in compliance with the Uniform Guidance and 2 CFR sections 200.318 through 200.326. Views of Responsible Officials - There is no disagreement with the audit finding.
Department of Agriculture, passed through Minnesota Department of Education Federal Financial Assistance Listing/CFDA Number 10.553/10.555 Child Nutrition Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria - Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition - In our testing of procurement, suspension, and debarment it was identified that there was no review of vendors to ensure that they are not suspended or debarred before purchases are made. Cause - Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect - A lack of compliant policies increases the overall risk of non-compliance. Questioned Costs - None reported Context/Sampling - Overall procurement policy. Repeat Finding from Prior Years - No Recommendation - We recommend that management establish a formal process to review vendors before purchases are made to ensure they are not suspended or debarred and are in compliance with the Uniform Guidance and 2 CFR sections 200.318 through 200.326. Views of Responsible Officials - There is no disagreement with the audit finding.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Federal Transit Cluster 20.507 AZ-90-X127 AZ-90-X132 AZ-90-X143 AZ-2018-003-00, AZ-2019-035, AZ-2020-030-00 AZ-2021-039 N/A Formula Grants For Rural Areas and Tribal Transit Program 20.509 GRT-20-0007- 926-T, CA-2019- 159-00, CA- 2021-028-00, CA-2021-031-00 N/A Federal Agency: Department of Transportation Pass-Through Agency: Arizona Department of Transportation and Quechan Indian Tribe Type of Finding: Noncompliance, Material Weakness Compliance Requirements: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of three quotes for purchases of at least $3,000 but less than $100,000 and formal bid procedures for purchases over $100,000. CONDITION YCIPTA did not follow its Board adopted Policies and Procedures Manual or federal regulations. CAUSE YCIPTA was operating under an expired contract and did not follow Board-adopted policies. EFFECT YCIPTA was not in compliance with the Board adopted Policies and Procedures Manual and federal regulations. CONTEXT During our review of procurement, the following were noted: ? For one purchase in excess of the federal procurement threshold of $250,000, YCIPTA did not perform a sealed bid or proposal. ? For one purchase in YCIPTA?s quote range, YCIPTA did not obtain or maintain quotes. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION YCIPTA should adhere to its Board adopted Policies and Procedures Manual. When purchases are expected to be in excess of $100,000, formal procurement methods should be used to ensure the best pricing possible. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Condition: The Organization has a procurement policy; however, the policy does not include all the elements required by the Uniform Guidance (UG). The policy should detail, among other items, thresholds and procedures for each of the five procurement methods, and how conflicts of interest are identified and addressed. Criteria: 2 CFR section 200.318 through 200.326 outlines the procurement standards and the elements that should be included in the Organization?s policy. Cause: Due to time restraints, the Organization has not yet updated its current policy. Effect: The effect is unknown. Recommendation: We recommend the Organization update its procurement policy with all the elements required by the UG.
Condition: The Organization has a procurement policy; however, the policy does not include all the elements required by the Uniform Guidance (UG). The policy should detail, among other items, thresholds and procedures for each of the five procurement methods, and how conflicts of interest are identified and addressed. Criteria: 2 CFR section 200.318 through 200.326 outlines the procurement standards and the elements that should be included in the Organization?s policy. Cause: Due to time restraints, the Organization has not yet updated its current policy. Effect: The effect is unknown. Recommendation: We recommend the Organization update its procurement policy with all the elements required by the UG.
Condition: The Organization has a procurement policy; however, the policy does not include all the elements required by the Uniform Guidance (UG). The policy should detail, among other items, thresholds and procedures for each of the five procurement methods, and how conflicts of interest are identified and addressed. Criteria: 2 CFR section 200.318 through 200.326 outlines the procurement standards and the elements that should be included in the Organization?s policy. Cause: Due to time restraints, the Organization has not yet updated its current policy. Effect: The effect is unknown. Recommendation: We recommend the Organization update its procurement policy with all the elements required by the UG.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Department of Energy, passed through Colorado Governor's Energy Office, Weatherization Assistance for Low-Income Persons/CFDA Number 81.042 for year ended June 30, 2022 Procurement Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR section 200.320(c), Noncompetitive Procurement, establishes there are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement can be awarded if the item/service is available only from a single source. Condition: The Organization has a written procurement policy for the year ended June 30, 2022 which established all the requirements of 2 CFR section 200.318 through 200.326 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), including 2 CFR section 200.320(c), Noncompetitive Procurement; however, documentation of compliance with the policy was not retained for one instance of a single-source vendor for services provided. Cause: In discussing the condition with the Organization?s personnel, the vendor was considered a single source, but proper documentation to this consideration was not maintained. Effect: Noncompliance with the Uniform Guidance could jeopardize future federal funding. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 40 transactions out of 684 total transactions were selected for procurement testing. Repeat Finding from Prior Years: No. Recommendation: The Organization should ensure documentation of compliance with all the requirements of Uniform Guidance, including 2 CFR section 200.320(c), Noncompetitive Procurement. We recommend that the Organization review, approve, and document process for any vendors which would qualify for noncompetitive procurement in the future. Views of Responsible Officials: Management agrees with the finding and will implement changes through a corrective action plan to ensure proper review, approval, and documentation of procurement policy.
2022-009 Prevailing Wage Rate Internal Control and Compliance CFDA Title: ESSER II CFDA Number: 84.425D Federal Award Number: 036-0648-92-2021 Federal Agency: Department of Education Pass-through Entity: Montana Office of Public Instruction Condition: The District did not require a contract indicating the requirement of prevailing wage rate and weekly certified payrolls submitted for federal construction project with contractor. Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141--3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Context: During th testing of expenditures for the ESSER II project we noted construction projects in excess of $2,000. Effect: The District was not in compliance with the prevailing wage rate requirement and the internal control system of the District did not identify the need for the compliance. Cause: Internal control procedures were not in place to ensure a contract was draw up to include the prevailing wage rate clause and to ensure the weekly certified payrolls were submitted to the District. Recommendation: The District should implement internal control procedures for any construction contracts in excess of $2,000 funded with federal monies include a contract with the prevailing wage rate clause and submission of weekly certified payrolls.
2022 ? 006 Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: FY 2021 and FY 2022 Pass-Through Agency: Indiana Department of Education Pass-Through Numbers: H027A190084, H027X210084, H173A180104, H173A210104, H173X10104 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.2 CFR 200.303 states in part: ?The Non-Federal entity must: (e) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: During testing, it was noted that the School did not retain documentation to support compliance with federal procurement standards. Questioned costs: $146,707 Context: For 7 of 7 vendors tested, no documentation was maintained to support the method of procurement, selection of contract type, contractor selection or rejection, or the basis for the contract price. The sample was a statistically valid sample. Cause: Lack of formal procedures over federal purchase. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation Repeat Finding: The finding is a repeat of a finding in the immediately prior audit report. Prior audit finding number was 2020-005. Recommendation: We recommend that School management establish a system of internal controls to ensure compliance with the grant agreement and procurement requirements of the procurement process. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 006 Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: FY 2021 and FY 2022 Pass-Through Agency: Indiana Department of Education Pass-Through Numbers: H027A190084, H027X210084, H173A180104, H173A210104, H173X10104 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.2 CFR 200.303 states in part: ?The Non-Federal entity must: (e) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: During testing, it was noted that the School did not retain documentation to support compliance with federal procurement standards. Questioned costs: $146,707 Context: For 7 of 7 vendors tested, no documentation was maintained to support the method of procurement, selection of contract type, contractor selection or rejection, or the basis for the contract price. The sample was a statistically valid sample. Cause: Lack of formal procedures over federal purchase. Effect: The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement or the compliance requirement could have resulted in the loss of federal funds to the School Corporation Repeat Finding: The finding is a repeat of a finding in the immediately prior audit report. Prior audit finding number was 2020-005. Recommendation: We recommend that School management establish a system of internal controls to ensure compliance with the grant agreement and procurement requirements of the procurement process. Views of responsible officials: There is no disagreement with the audit finding.